Privacy Policy

Privacy Policy as of November 17th, 2020

Closing Time Photography. is a responsible member of the unmanned aircraft systems (“UAS”) community. We try to do our part to ensure that UAS achieve their full potential. To that end, Closing Time Photography strives to operate in a responsible and ethical manner, with a commitment to transparency, privacy, and accountability. We know that our customers and members of the public who may be affected by our operations care about how information about them is collected, used, and shared. We appreciate your trust that we will do so carefully and sensibly. We take your privacy seriously. By visiting www.closingtimephotos.com or using our services, customers, and visitors visiting our website are accepting the practices described in this Privacy Policy.

What Does This Privacy Policy Cover?
This policy covers how Closing Time Photography treats personal information that Closing Time Photography collects and receives. For customers or website visitors, this includes information (i) related to your application for and use of Closing Time Photography products and services and (ii) about you that is personally identifiable information (“PII”), such as your name, address, email address, or phone number. Collectively, this information is referred to as “Customer Information”.

For members of the public, this policy applies to “Covered Data,” which means information collected by Closing Time Photography in the course of providing UAS services that identifies or could be used to identify a particular person. If data collected by a UAS likely will not be linked to an individual’s name or other PII, or if the data is altered so that a specific person is not recognizable, it is not Covered Data. We generally follow the NTIA Voluntary Best Practices for UAS Privacy, Transparency, and Accountability, which are available here.

This Privacy Policy is not intended to create any type of contract or warranty with regard to individuals and Covered Data; rather, it is only intended to be informational. This Policy also does not apply to the practices of our customers or to other companies that are not affiliated with Closing Time Photography.

Use, Sharing, And Disclosure of Customer Information
Information about our customers is crucial to our business. We use Customer Information to provide and bill for our services and to improve and personalize those services. We do not share Customer Information with third parties for their commercial use, although we may provide it to our subcontractors or service providers who are assisting us in our business. We disclose Customer Information to other third parties only in the following situations:

• We may respond to subpoenas, court orders, or other legal requirements, or seek to establish or exercise our legal rights or defend against legal claims.
• We believe it is necessary to disclose such information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Closing Time Photography’ Terms of Service.

If Closing Time Photography is acquired by or merged with another company, the terms of this Privacy Policy shall continue to apply. In this event, Closing Time Photography will notify you before information about you is transferred and becomes subject to a different privacy policy.

Closing Time Photography also reserves the right to display targeted advertisements based on personal information.

Notice of Collection, and Sharing, Use and Retention of Covered Data
Where practicable, Closing Time Photography will make a reasonable effort to provide prior public notice of the general timeframe and area that a Closing Time Photography UAS may be collecting Covered Data. This notice may be provided by a public posting on our website or in the physical vicinity of the target area, or by specific communications to identifiable individuals likely to be in the target area during the operations. The notice will generally identify the purposes for which the UAS will be collecting data (e.g., an inspection of farm fields or cell towers) and the kinds of data the UAS will collect (e.g., photographs, video, or LIDAR images).

Where it will not conflict with FAA rules or guidelines, Closing Time Photography will make a reasonable effort to minimize UAS operations over the private real property without the consent of the property owner. This, in turn, should minimize the inadvertent collection of Covered Data. In addition, absent a contractual requirement or consent of the affected individuals, Closing Time Photography’ policy is to avoid using UAS for the specific purposes of

– intentionally collecting Covered Data where we know the data subject has a reasonable expectation of privacy; or

– persistent and continuous collection of Covered Data about individuals.

Covered Data that is acquired by Closing Time Photography in the course of providing services to a customer will usually be provided to the customer in near real-time as part of the data dump without applying any obfuscation or de-identification practices (such as blurring faces or license plates). Closing Time Photography will require that its customers not use Covered Data for any of the following purposes without the consent of the individual involved unless expressly permitted by and subject to the requirements of a sector-specific regulatory framework: employment eligibility, promotion, or retention; credit eligibility; or health care treatment eligibility.

Covered Data acquired in the course of providing services to one customer will not be shared by us with any other customer. We may retain a copy of customer data that includes Covered Data. If we use such data for marketing or educational purposes or otherwise display it publicly, we will make a reasonable effort to obfuscate or de-identify any included Covered Data. The period for which we will retain data (including Covered Data) cannot be specified because it depends on, among other things, customer requirements, evolving business operations, and legal requirements.

If you have questions about the privacy or security of Covered Data, including requests to obfuscate or delete Covered Data involving you, please contact us at southbaydrone@gmail.com.

Confidentiality And Security
Closing Time Photography is committed to protecting the security of Customer Information and Covered Data. We use a variety of industry-standard security technologies and procedures to help protect such information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer systems with limited access, which are located in access-controlled facilities. When we transmit highly confidential information (such as a credit card number) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Closing Time Photography also limits internal access to the information to employees, subcontractors, and service providers who we reasonably believe require this information in order to do their jobs or to provide services to you.

Conclusion
Closing Time Photography may update this policy at any time. We will notify customers about any substantive changes in the way we treat your PII by sending a notice to the primary email address you specified in your Closing Time Photography account application or by placing a notice in a prominent place on our website. If you have further questions or suggestions regarding Closing Time Photography’ Privacy Policy, you can contact us at southbaydrone@gmail.com.